E

4 ALBERT EMBANKMENT
LONDON SE1 7SR
Telephone: +44 (0)20 7735 7611 Fax: +44 (0)20 7587 3210

MEPC.1/Circ.878
9 November 2018

GUIDANCE ON THE DEVELOPMENT OF A SHIP IMPLEMENTATION PLAN FOR THE

CONSISTENT IMPLEMENTATION OF THE 0.50% SULPHUR LIMIT
UNDER MARPOL ANNEX VI

1 The Marine Environment Protection Committee, at its seventy-third session

(22 to 26 October 2018), approved the Guidance on the development of a ship implementation
plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, as
set out in the annex.

2 Member Governments are invited to bring the annexed Guidance to the attention of
their Administration, industry, relevant shipping organizations, shipping companies and other
stakeholders concerned.

***

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ANNEX

GUIDANCE ON THE DEVELOPMENT OF A SHIP IMPLEMENTATION PLAN

FOR THE CONSISTENT IMPLEMENTATION OF
THE 0.50% SULPHUR LIMIT UNDER MARPOL ANNEX VI

Introduction

1 MEPC 70 agreed to "1 January 2020" as the effective date of implementation for ships
to comply with global 0.50% m/m sulphur content of fuel oil requirement and adopted
resolution MEPC.280(70) on the Effective date of implementation of the fuel oil standard in
regulation 14.1.3 of MARPOL Annex VI1.

2 In this context, MEPC 73 agreed that Administrations should encourage ships flying
their flag to develop implementation plans, outlining how the ship may prepare in order to
comply with the required sulphur content limit of 0.50% by 1 January 2020. The plan could be
complemented with a record of actions taken by the ship in order to be compliant by the
applicable date.

3 Regulation 18.2.3 of MARPOL Annex VI requires a Party to take into account all
relevant circumstances and the evidence presented to determine the action to take, including
not taking control measures. Administrations and port State control authorities may take into
account the implementation plan when verifying compliance with the 0.50% sulphur limit
requirement.

4 A ship implementation plan is not a mandatory requirement. A lack of a ship

implementation plan or an incomplete ship implementation plan should not be considered as
"clear grounds" for a more detailed inspection.

Ship implementation plan for the consistent implementation of 0.50% sulphur limit
under MARPOL Annex VI

5 The ship implementation plan for 2020 could cover various items relevant for the
specific ship, including, as appropriate, but not limited to:

.1 risk assessment and mitigation plan (impact of new fuels);

.2 fuel oil system modifications and tank cleaning (if needed);

.3 fuel oil capacity and segregation capability;

.4 procurement of compliant fuel;

.5 fuel oil changeover plan (conventional residual fuel oils to 0.50% sulphur
compliant fuel oil); and

.6 documentation and reporting.

1 Amendments to regulation 14.1.3 of MARPOL Annex VI were adopted by MEPC 73 (October 2018).

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Issues relating to use of sulphur compliant fuel oil

6 All fuel oil supplied to a ship shall comply with regulation 18.3 of MARPOL Annex VI
and chapter II/2 of SOLAS. Furthermore, ship operators could consider ordering fuel oil
specified in accordance with the ISO 8217 marine fuel standard. The following potential
fuel-related issues may need to be assessed and addressed by ships in preparation for and
implementation of the 0.50% sulphur limit requirement:

.1 technical capability of ships to handle different types of fuel (e.g. suitability of

fuel pumps to handle both higher and lower viscosity fuels, restrictions on
fuels suitable for use in a ship's boilers, particularly the use of distillate fuels
in large marine boilers);

.2 compatibility of different types of fuels e.g. when paraffinic and aromatic fuels
containing asphaltenes are commingled in bunkering or fuel oil changeover;

.3 handling sulphur non-compliant fuels in the event of non-availability of

sulphur compliant fuels; and

.4 crew preparedness including possible training with changeover procedures

during fuel switching from residual fuel oil to 0.50% compliant fuel oils.

7 The ship implementation plan could be used as the appropriate tool to identify any
specific safety risks related to sulphur compliant fuel oil, as may be relevant to the ship, and to
develop an appropriate action plan for the Company to address and mitigate the concerns
identified. Examples should include:

.1 procedures to segregate different types of fuel and fuels from different

sources;

.2 detailed procedures for compatibility testing and segregating fuels from

different sources until compatibility can be confirmed;

.3 procedures to changeover from one type of fuel to another or a fuel oil that
is known to be incompatible with another fuel oil;

.4 plans to address any mechanical constraints with respect to handling specific

fuels, including ensuring that minimum/maximum characteristics of fuel oil as
identified in ISO 8217 can be safely handled on board the ship; and

.5 procedures to verify machinery performance on fuel oil with characteristics

with which the ship does not have prior experience.

8 A ship implementation plan for the consistent implementation of the 0.50% sulphur limit
under MARPOL Annex VI is recommended to be developed based on the indicative example
as set out in appendix 1.

9 The plan could take into account the issues identified in:

.1 appendix 2: additional guidance on development of ship implementation plan

(impact on machinery systems); and

.2 appendix 3: additional guidance on development of ship implementation plan

(tank cleaning).

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APPENDIX 1

INDICATIVE EXAMPLE FOR SHIP IMPLEMENTATION PLAN FOR ACHIEVING

COMPLIANCE WITH THE 0.50% SULPHUR LIMIT ENTERING INTO FORCE ON
1 JANUARY 2020 USING COMPLIANT FUEL OIL ONLY

Particulars of ship

1. Name of ship:

2. Distinctive number or letters:

3. IMO Number:

Planning and preparation (before 1 January 2020)

1 Risk assessment and mitigation plan

1.1 Risk assessment (impact of new fuels): YES/NO

1.2 Linked to onboard SMS YES/NO

2 Fuel oil system modifications and tank cleaning (if needed)

2.1 Schedule for meeting with manufacturers and/or classification societies:

2.2 Structural Modifications (installation of fuel oil systems/tankage) required:

YES/NO/NOT APPLICABLE

If YES, then:

2.2.1 Fuel oil storage system:

Description of modification:

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Details of yard booking (as applicable), time schedules etc.:

Estimated date of completion of modification:

2.2.2 Fuel transfer, filtration and delivery systems:

Description of modification:

Details of yard booking (as applicable), time schedules etc.:

Estimated date of completion of modification:

2.2.3 Combustion equipment:

Description of modification:

Details of yard booking (as applicable), time schedules etc.:

Estimated date of completion of modification:

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2.3 Tank cleaning required: YES/NO/NOT APPLICABLE

If YES, then:

Details of cleaning schedule (including, yard booking, time schedules etc., if

applicable):

Estimated date of completion of cleaning:

3 Fuel oil capacity and segregation capability:

Following any required modifications as per Section 2:

3.1 Expected number of bunker tanks designated to store 0.50% sulphur

compliant fuel oil:

3.2 Expected total storage capacity (m3) for 0.50% sulphur compliant fuel oil:

3.3 Expected number of bunker tanks designated to store 0.10% sulphur

compliant fuel oil:

3.4 Expected total storage capacity (m3) for 0.10% sulphur compliant fuel oil:

3.5 Approximate total fuel oil content (m3) in the fuel oil transfer, purification and
delivery systems:

4 Procurement of compliant fuel oil

4.1 Details of fuel purchasing procedure to source compliant fuels, including

procedures in cases where compliant fuel oil is not readily available:

4.2 Estimated date for bunkering compliant fuel oil, not later than 24:00hrs
31 December 2019:

4.3 If fuel arranged by charterer, is there an intention to accept charter party

contracts that do not have a specified obligation to provide compliant fuel oil
after 1 June 2019 or other date to be identified: YES/NO

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If YES, then:

Details of alternate steps taken to ensure that the charter party provides timely
delivery of compliant fuel:

4.4 Is there confirmation from bunker supplier(s) to provide compliant fuel oil on
the specified date: YES/NO

If NO, then:
Details of alternate steps taken to ensure timely availability of compliant fuel oil:

4.5 Details of arrangements (if any planned) to dispose of any remaining

non-compliant fuel oil:

5 Fuel oil changeover plan

5.1 Consider whether a ship-specific fuel changeover plan is to be made

available. The plan should include measures to offload or consume any
remaining non-compliant fuel oil. The plan should also demonstrate how the
ship intends to ensure that all its combustion units will be using compliant
fuel oil no later than 1 January 2020.

5.2 As per the ship-specific fuel changeover plan, the maximum time period
required to changeover the ship's fuel oil system to use compliant fuel oil at
all combustion units:

5.3 Expected date and approximate time of completion of the above-mentioned

changeover procedure:

5.4 Consider availability of adequately trained officers and crew familiar with the
ship's fuel system and fuel changeover procedures to carry out the fuel oil
changeover procedure. If this cannot be confirmed, then consider whether
there is a sufficient amount of time dedicated for ship-specific familiarization
and training of new officers and crew.

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6 Documentation and reporting

6.1 If there are modifications planned as per section 2, related documents

including the shipboard fuel oil tank management plans and stability and trim
booklets should be consequently updated.

6.2 The implementation plan could be kept on board and updated as applicable.

6.3 If when following the implementation plan the ship has to bunker and use
non-compliant fuel oil due to unavailability of compliant fuel oil safe for use
on board the ship, steps to limit the impact of using non-compliant fuel oil
could be:

6.4 The ship should have a procedure for Fuel Oil Non-Availability Reporting
(FONAR). The master and chief engineer should be conversant about when
and how FONAR should be used and who it should be reported to.

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APPENDIX 2

ADDITIONAL GUIDANCE FOR DEVELOPMENT OF THE SHIP IMPLEMENTATION PLAN

(IMPACT ON MACHINERY SYSTEMS)

1 Ships are advised to assess potential impact on machinery systems with the use of
distillates and fuel oil blends and prepare ships in consultation with chief engineers, equipment
manufacturers and suppliers.

2 The ship tank configuration and fuel system may require adjustments. A fully
segregated fuel system for distillate fuels and blended fuels is recommended because they
may require special attention. Ship tank configuration and segregated fuel system will also
allow for better management of potentially incompatible fuels.

Distillates

3 If distillates have been chosen as the option for compliance the following may be
considered:

.1 a decrease in fuel oil viscosity may cause an increase in fuel oil leakage
between the fuel pump plunger and barrel of diesel engines. Internal
leakages in the fuel injection system may result in reduced fuel pressure to
the engine, which may have consequences for the engine performance
(e.g. starting of the engine). Equipment makers' recommendations should be
consulted, and adequate testing, maintenance and possible installation of
coolers etc. may be performed;

.2 shipowners may also consider installing fuel pumps and injection nozzles,
suitable to fuel oil with low viscosity. Fuel oil with too low viscosity may lead
to increased wear or seizure of fuel oil pumps. Engine and boilermakers
should be consulted to ensure its safe and efficient operation. Implications
for validity of NOX certification (EIAPP Certificate) should be considered;

.3 while some compliant fuels may not require heating, others, including some
distillates, will require heating. It would therefore be prudent to review heating
arrangements for distillate fuels on board and, where appropriate, maintain
the existing heating arrangements; and

.4 in some locations, bunker suppliers may only be able to offer automotive

diesel fuel containing biodiesel (FAME) in accordance with the
ISO 8217-2017 Standard which provides a marine biodiesel specification
(DFA/DFB) with up to 7.0% by volume of FAME. CIMAC has provided a
"Guideline for Ship Owners and Operators on Managing Distillate Fuels up
to 7.0 % v/v Fame (Biodiesel)".2

4 In view of paragraph 3.3 manufacturers of engines and equipment such as oily water
separators, overboard discharge monitors, filters and coalescers, etc. need to be consulted to
confirm ability to handle biodiesel blends up to 7% v/v.

5 Also, some parts of the fuel oil supply system, i.e. fuel pumps, pipefittings and gaskets
may need to be overhauled to ensure integrity.

2
https://www.cimac.com/cms/upload/workinggroups/WG7/CIMAC_WG7_Guideline_for_Ship_Owners_and_Oper
ators_on_Managing_Distillate_Fuels_May_2013.pdf

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Blended residual fuels

6 New blended 0.50% sulphur fuel oil as and when offered could provide an alternative
to conventional distillate fuel such as Marine Distillate Fuel.

7 When using such new blended sulphur fuel oils, the technical specification of such
fuels are (a) either within the limits specified by ISO 8217 or are (b) issued with formal
documentation indicating no objection to its use by the engine/boiler makers.

8 Before purchasing a new fuel oil product, operators should carefully consider the
specific technical and operational challenges that this type of fuel oil may have and, where
necessary, contact the fuel oil supplier or Original Equipment Manufacturer (OEM) for the
considerations to be made to ensure safe operation.

9 Densities of these fuel oils are in general lower than conventional residual fuel oils.
This may require adjustment of centrifuges to ensure adequate cleaning of the fuel oil.

Cold flow

10 Since most distillate fuels do not require heating (in fact, typically, heating is not
recommended due to the low viscosity of these products), the fuel's cold flow properties
become a potential handling/storage challenge, especially when operating in colder regions.

11 It is however possible to successfully manage cold flow properties through good fuel
management, from procurement to technical operation, by considering the following:

.1 where the ship will be operating;

.2 where the risk is higher of getting fuels with poor cold flow properties;

.3 can the required cold flow properties be specified in the fuel contract;

.4 what is the actual low-temperature flow properties of the bunkered fuel; and

.5 which actions have to be taken in order to safely consume the bunkered fuel
(e.g. tank and filter heating).

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APPENDIX 3

ADDITIONAL GUIDANCE FOR DEVELOPMENT OF THE SHIP IMPLEMENTATION PLAN

(TANK CLEANING)

Introduction

1 Most ships will have been using high viscosity high sulphur fuel oil (HSFO) based
primarily on residual fuel oils. Such fuels tend to adhere to the inside of fuel tanks forming
layers of semi-solid substances containing sediments and asphaltenic sludge; such residues
will also typically have solidified and settled in various parts of the fuel oil service system
including pipelines, settling and service tanks.

2 The ship operator may choose to clean the fuel oil tanks of these residues before
loading compliant fuel prior to 1 January 2020 based on the following considerations.

3 Some of the fuels complying with the 0.50% sulphur limit are expected to be very
paraffinic due to crude sources of blending components and also a high content of distillate
components. If such fuels are loaded into HSFO fuel tanks that have not been cleaned, there
is a possibility that they could dissolve and dislodge sediments and asphaltenic sludge in
storage tanks, settling tanks and pipelines, potentially leading to purifier and filter operational
issues and in extreme cases fuel starvation resulting in loss of power.

4 Alternatively, ships have been using ship specific changeover procedures to

effectively and safely load on top of existing fuel oil and gradually flushing through the fuel
system until the sulphur content in the fuel oil is at a compliant level.

5 Should the ship operator determine it is appropriate to clean the ship's fuel oil tanks
and system, the following considerations may need to be taken into account when making
arrangements for tank cleaning.

Options for tank cleaning, approximate timelines and considerations

6 Fuel oil tanks are normally cleaned on a regular basis on ships to remove built-up
sediments and sludge, usually during dry docking and whenever inspections of the fuel tanks
are due. However, leading up to 1 January 2020, it would not be practicable for the majority of
the global fleet that has been running on HSFO and decided to opt for tank cleaning to undergo
dry docking during a very short period. Hence, other options for cleaning tanks and fuel oil
systems during service may need to be considered.

7 The time and work involved in cleaning HSFO tanks cannot be defined precisely, as
it will vary depending on how long it has been since the last time the tanks were cleaned, the
condition of the tank coating and the effectiveness of the cleaning process itself. The estimates
in this document may err on the side of caution as it is almost impossible to pinpoint at what
stage the ship's fuel oil system is sufficiently clean to guarantee compliance.

Manual cleaning during dry docking

8 Time required varies; it can be done in 2 to 4 days per tank. In addition to cleaning
tanks, all of the pipework in the fuel oil service system needs to be flushed through. Overall, it
may take 1 to 2 weeks.

9 A ship that has had all its fuel oil tanks and fuel system cleaned can start loading
compliant fuels and expect to be fully compliant right away.

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10 However, if only the tanks have been cleaned in dry dock, it could take 2 to 5 days to
flush through the pipework in the fuel oil service system to ensure full compliance with
the 0.50% sulphur limit.

Manual cleaning during service

11 If tanks are to be cleaned manually during service, risk assessment and safety
measures are paramount; refer to IMO resolution A.1050(27) on Revised recommendations
for entering enclosed spaces aboard ships.

12 Time required will vary depending on tank size and the number of tanks, how long it
has been since the last tank cleaning and the number of crew available to perform safe and
complete tank cleaning operations. Tank cleaning can be performed by the ship's crew and/or
by employing a riding crew for this purpose. It is always good practice to inspect the tank once
cleaned to check its condition and to inspect heating coils, conduct pressure tests and
undertake repairs as necessary.

13 If the cleaning is done by the ship's existing crew, it would likely take a minimum
of 4 days per tank. For an average tank, a week should be allowed. If employing a riding crew
to clean the tanks, if working in shifts, it would likely take a minimum of 2 days to clean a tank,
but 4 days per tank should be allowed.

14 Tanks need to be empty before they can be cleaned, hence the time needed to drain
tanks needs to be taken into account when estimating the overall time required.

15 In addition to cleaning tanks, all of the pipework in the fuel oil service system needs
to be flushed. Flushing the remaining pipework and fuel oil service system after all tanks have
been cleaned could take another 1 to 2 days.

16 The residues from tank cleaning should be retained on board until they can be
disposed of correctly or disposed to shore reception facilities.

Cleaning tanks in service with specialized additives

17 As an alternative to manual cleaning, consideration can be given to gradually cleaning

the sediments and asphaltenic sludge from HSFO tanks and fuel systems by dosing additives.
There are successful examples of this approach for ships that needed to reallocate HSFO
tanks to fuels complying with the 0.10% sulphur limit that took effect in ECAs in 2015.

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